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Last updated on October 10th, 2018
WireMasters GmbH & Co. KG (“WireMasters Germany” “we”, “us”, or “our”) believe in transparency and are committed to informing you, our website visitor / customer (“you”, “your”, or “user”), about how we treat your personal data and the rights and options that you have with regard to your personal data. Under applicable data protection laws, personal data means any information that identifies a natural person or makesthat person identifiable. It generally does not include data where the person's identity has been removed (anonymized data).
Who Is Responsible For Your Personal Data?
WireMasters GmbH & Co. KG (WireMasters Germany)
Zum Sonnenberg 7-11
Telephone: +49 (0)60 51 60 60-0
WireMasters Germany is the data controller and, as such, is responsible, alone or jointly with others, for deciding on the purposes and means of processing your personal data.
Our parent company, with whom we may disclose your personal data to the extent described in the section “Disclosure Of Personal Data” is:
WireMasters, Inc. (hereinafter WireMasters USA)
1788 Northpointe Road
Columbia, TN 38401
For all data shared with WireMasters USA, WireMasters Germany and WireMasters USA are joint controllers pursuant to Art. 26 GDPR.
What Personal Data Do We Collect
We may collect, process, store, and transfer the following types of personal data from you, as identified by category below:
Identity and Contact Data includes first name, maiden name, last name, username or similar identifier, title, billing address, delivery address, email address, and/or telephone numbers.
Financial and Payment Data includes your bank account and other data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information.
Business Information includes information provided in the course of the contractual or client relationship between you or your organization and us, or otherwise voluntarily provided by you or your organization
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, and feedback.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Special Categories of Personal Data
With the exception of data from job applicants, we do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If You Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services) or fail to comply with our legal obligations. In this case, we may, for example, have to cancel a product or service you have with us and will notify you if that occurs.
Why Do We Collect Personal Data?
We generally collect data from and about you through the following means and for the following purposes. The indicated legal basis for the describe processing refers to the GDPR:
Types of Data and Purpose
Contact Information / Feedback / Inquiries
When you submit feedback to us, contact us for support, or ask us questions, we collect your name, email address, postal address, telephone number, and/or other contact information necessary to respond to your feedback, provide support, or answer your question. We will, therefore, process any data you enter into a contact form or other communication with us in order to enter into a contract or for the performance of an existing contract with you, Art. 6 (1)(b) GDPR, or for pursuing our legitimate interest in responding to your communication, Art. 6 (1)(f) GDPR.
User Account Information
When you create an account, we collect your contact information and ask if you would like to submit other personal data, in addition to your username, your password, and registration information. We do this in order to provide you with password-protected access to the account you requested and allow you to maintain your account profile and access certain interactive Website features. We will, therefore, process any data you submit in the context of your user account in order to establish a contractual relationship or for the performance of an existing contract with you, Art. 6 (1)(b) GDPR, or for pursuing our legitimate interest in providing you with additional features of our Website, Art. 6 (1)(f) GDPR. Collected customer data shall be deleted after completion of the order or termination of the business relationship. Legal retention periods remain unaffected.
When you seek services from us in the course of our contractual or customer relationships between you and/or your organization, we collect business contact information and other personal data in order to provide you with the services you have requested. The basis for data processing is Art. 6 (1) (b) GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.
When you visit our Website, we may collect cookies and use similar technologies to, among other things, provide you with a more personal and interactive experience on our Website, to improve our marketing efforts, and for website usage analytics. Please see our Cookies Policy for more information on your options regarding the use of cookie. If you choose to disable cookies and similar technologies, some areas and features of the Website may not work properly.
If you receive email communications from us, we may use certain tools to capture data related to when you open our messages, click on hyperlinks or banners it may contain, and make purchases. We use this information to enhance and support our marketing and sales operations, and therefore for the pursuit of our legitimate interests, Art. 6 (1)(f) GDPR.
If you apply for a job we collect personal data necessary to process your application or employment. This may include, among other things, your contact information, social security number, employment history, etc..We will process your application data in order to consider whether to enter into an employment contract with you, § 26 BDSG (German Federal Data Protection Act).
Newsletters and Marketing
When you sign up for our newsletters or other marketing lists, we collect your contact information, including your email address, phone number, and/or postal address. We process this personal data based on your consent, Art. 6 (1)(a) GDPR. You are free to withdraw your consent at any time. The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription and then the data will be deleted. Data we have stored for other purposes (e.g. email addresses for the members area) remain unaffected.
Additional Purposes For Which We Process Your Personal Data
In addition to the specific categories of data use above, we may with your express consent and/or under recognized legal grounds, also use your personal data for the following purposes:
- To provide you with services you have requested and to manage our relationship with you, including administering your account, processing payments, accounting, auditing, billing and collection and taking other steps necessary to the performance of our business relationship with you (performance of a contract, Art. 6 (1)(b) GDPR);
- To present and improve Website contact and functionality (pursuit of legitimate interests, Art. 6 (1)(f) GDPR);
- To determine user interests, needs, and preferences (pursuit of legitimate interests, Art. 6 (1)(f) GDPR);
- To provide notice of changes to our Website or the services we offer or provide through it (with your consent, Art. 6 (1)(a) GDPR and/or for the pursuit of legitimate interests, Art. 6 (1)(f) GDPR);
- To conduct research and analysis (pursuit of legitimate interests, Art. 6 (1)(f) GDPR);
- To develop new products and services (pursuit of legitimate interests, Art. 6 (1)(f) GDPR);
- To manage and maintain the security of our Website and services (pursuit of legitimate interests, Art. 6 (1)(f) GDPR);
- To market our services to you. We will only provide you with marketing-related information after you have, where legally required to do so, opted in to receive those communications and having provided you with the opportunity to opt-out of such communications at any time (consent, Art. 6 (1)(a) GDPR).
- To comply with our legal and compliance obligations, including maintaining records, performing compliance audits, etc. (compliance with legal obligations, Art. 6 (1)(c) GDPR).
- For insurance purposes (pursuit of legitimate interests, Art. 6 (1)(f) GDPR);
- To exercise and defend our legal rights, or to comply with court orders (pursuit of legitimate interests, Art. 6 (1)(f) GDPR);
- To respond to requests from public and government authorities (compliance with legal obligation, Art. 6 (1)(c) GDPR; pursuit of legitimate interests, Art. 6 (1)(f) GDPR);
- In any other way we may describe when you provide the information; and
- For any other purpose to which you have expressly consented (Art. 6 (1)(a) GDPR).
With regard to consent, the form and means of the consent obtained may vary according to the sensitivity of the personal data, the reasons we are collecting it, and the reasonable expectations of the person from whom it is collected. When using personal data for a new purpose, we will document that new purpose and ask for consent again. You may revoke your consent at any time with future effect.
We do not use your personal data for making any automated decisions affecting or creating profiles other than as described above and welcome your questions and feedback about the nature and lawful bases of our processing activities.
Disclosure Of Your Personal Data
We do not sell, rent, or lease your personal data to third parties. We may, however, share your personal data in the following contexts:
Disclosures Without Your Consent
We may disclose your personal data in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws or regulatory investigations when we believe in good faith that applicable law requires it (compliance with legal obligations, Art. 6 (1)(c) GDPR). We may also share your personal data in order to establish or exercise our legal rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property or a violation of our Website terms and conditions. In addition we will disclose all personal data relating to our business relationship with you, including all Identity and Contact Data; Financial and Payment Data; Business Information; Transactional Data and Marketing and Communications Data with our parent company WireMaster in the U.S.A. for reasons of customer management, order processing (performance of contract, Art. 6 (1)(b) GDPR), marketing and supervision of our overall business performance (pursuit of legitimate interests, Art. 6 (1)(f) GDPR).
As far as the processing and disclosure is based on our legitimate interests, you have the right to object. Please see the lists of your rights further below.
Disclosures With Your Consent
Job applications and Employment
If you apply for a job with us, we may disclose personal data necessary to process your application. This may include, among other things, your contact information, your social security number, employment history, etc. in accordance with applicable law (prior to entering into a contract, § 26 BDSG).
Feedback / Support / Inquiries
If you provide us with feedback, contact us for support, or ask us questions via web form, telephone, email, or other method allowed by our Website, we will collect and may disclose your name, email address, other contact information and other information as needed to respond to your feedback, request for support, or answer your question.
Employees, business affiliates, and intermediaries
Mailing List and Newsletters
When you sign up for one of our mailing lists or newsletters, we disclose your contact information, including your name, company name, email address, postal address, and telephone, to our marketing service providers as necessary to complete and process your sign up and manage subscription.
If necessary for the purposes outlined above, we may share your personal data with our Service Providers. Among other things, Service Providers may help us to administer the Website, support our provision of products and services requested by you, provide technical support, send marketing and promotions and communicate with you about our products and services, payment processing issues, and other legitimate purposes permitted by law, Article 6 (1) lit. f DSGVO. Please also see the section “Third Parties” below for more information.
We may sell, transfer or otherwise share some or all of our assets in connection with a merger, reorganization or sale of assets, or in the event of bankruptcy, without your permission. In such an event, your personal data may among the assets be transferred.
We may disclose aggregated (anonymized) information about our website visitors, and information that does not identify any specific individual, such as groupings of demographic data and customer preferences, for new product and marketing development and website improvements.
Our Website may be developed and supported by third party vendors, who may, in the course of performing such services for us (such as hosting, developing, or updating our Website), have access to your personal data. We contractually require such vendors to maintain the confidentiality of your information, and take appropriate measures to keep it secure. We prohibit such vendors from using or sharing your information for any purpose other than in performing specific services for us required to maintain and update our Website.
Our vendors may periodically access our web server and/or employ analytics technologies during the course of their work that may automatically collect and store the following general information about you: the originating name of the domain from which you access the Internet; the date and time you access the Website; the pages of the Website you visit; the Internet address of the website from which you linked directly to the Website; and the type of device, device ID, and browser you use to access the Website. This information is used to help us improve the Website by tabulating statistics about your use of our Website, such as error incidence and origin of referrers, that allow us to make the Website more useful to you.
One such third party vendor is Google Analytics and its related suite of services to collect information about the use of the website. Google application programming interfaces are used to facilitate communication with Google Services. We use Google Analytics to gather information about how the Website is used in order to determine the best ways to improve the user experience, as further explained in our Cookies Policy.
In addition to aggregated data, we also may receive or disclose personal data about you from various third parties, inside and outside of the EU/EAA, who are bound to obligations of confidentiality and required to perform processing with us or on behalf only for as long as required by role and contract or business relationship with us. The types of personal data and third parties involved in these activities include: Contact, Financial and Transaction Data with providers of technical, payment and delivery services inside and outside of the EU, Usage Data with service providers who provide additional IT and system administration services, and Business Information and Transaction Data with professional advisers including lawyers, bankers, auditors, and insurers based in who provide consultancy, banking, legal, insurance and accounting services. As far as these third parties act as our processors (only process personal data on our behalf and under our instruction), we enter into data processing agreements with these parties. Where these third parties do not only process your data on our behalf, we take appropriate measures to protect your personal data. Please contact us with if you have any further questions on these third parties or the business and legal purposes for which we make such disclosures.
How Long Do We Store Your Personal Data?
We will retain your personal data for as long as needed to fulfill the purposes for which it was collected. We also will retain and use your personal data as long as necessary to comply with our business requirements, legal obligations especially legally required retention times, resolve disputes, protect our assets, provide our services, and enforce our agreements. In general, information on performed business transactions will be blocked from general access within 2 years after completion of the transaction and deleted once statutory retention requirements expire. For example, national commercial or financial codes may require to retain certain information for up to 10 years. Afterwards, we will securely destroy your personal data in accordance with applicable law and our policies. In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
How Do We Safeguard Your Information On International Data Transfers?
As our parent company WireMaster USA is located in the USA, parts of your personal data, will be processed and stored in the USA (for the extent of disclosure see above). Also we may share data with Service Providers who are located in the USA as well. If you are in the EU or EEA, this may mean that your personal data will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal data than the jurisdiction you are typically a resident in.
If we transfer information from the EU to third parties outside the EU and to countries not subject to schemes which are considered as providing an adequate data protection standard, we will either enter into contracts which are based on the EU Standard Contractual Clauses with these parties or ensure an adequate level of protection by other means (such as the EU-U.S. Privacy Shield).
Insofar as WireMasters Germany and WireMasters USA are joint controllers, for example, in relation to all data stored in the enterprise resources management program or in our data base for managing the customer relationship, both parties are bound by a joint controller agreement in accordance with Art. 26 GDPR. In particular, both parties have agreed on appointing WireMasters Germany as the main contact and responsible entity for all of the below listed tasks:
Notification (Art. 13, 14 GDPR)
Access (Art. 15, 19 GDPR)
Rectification (Art. 16, 19 GDPR)
Erasure (Art. 17, 19 GDPR)
Restriction of Processing (Art. 18, 19 GDPR)
Data Portability (Art. 20 GDPR)
Objection (Art. 21 GDPR)
Automated decision-making (Art. 22 GDPR), if applicable
Data Protection Impact Assessment (Art. 35, 36 GDPR)
On request, we will make a copy of these clauses available.
Updating Your Personal Data
If any of the personal data you have provided to us changes, please let us know. For instance, if your email changes, you wish to cancel any request you have made of us, or if you become aware of inaccurate personal data about you, use our Contact Us details to update your information. You may also edit your account details if you have a user account through our Website.
Your Rights To Access And Control Your Personal Data
RIGHT TO OBJECT. YOU HAVE THE RIGHT TO OBJECT TO ANY PROCESSING BASED ON OUR LEGITIMATE INTERESTS WHERE THERE ARE GROUNDS RELATING TO YOUR PARTICULAR SITUATION. FURTHERMORE YOU CAN OBJECT TO MARKETING ACTIVITIES FOR WHATEVER REASON WHATOSEVER AT ANY TIME..
Right of Access. You have the right to obtain access to your personal data. You can request a copy of the personal data that we hold about you, as well as inquire about the origin, recipients, and purposes of processing that data. There are certain exceptions to this right, however, so that we may deny access to you as required by law or to protect the legal rights of others.
Right to Rectification. You have the right to request rectification of your personal data without undue delay where that personal information is inaccurate or incomplete.
Right to Portability. You have the right to request that some of your personal data is provided to you or an authorized third party in a commonly-used, machine-readable format. If you require the direct transfer of data to another responsible party, this will only be done to the extent technically feasible.
Right to Restriction. You have the right to request restriction of the processing undertaken by us on your personal data in certain circumstances, such as, where the accuracy of the personal data is contested by you, for a period of time enabling us to verify the accuracy of that personal data.
We may decide to delete your personal data if we believe it is incomplete, inaccurate or that our continued storage of your personal data is contrary to our legal obligations or business objectives. We may retain your personal data as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.
Once we have received notice that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented.
Withdrawal of consent to receive marketing communications will not affect the processing of personal data for the provision of our services.
The supervisory authority for data protection responsible for us is:
Der Hessische Datenschutzbeauftragte
You have the right to complain at any time to your local data protection authority or to the referred data protection authority in the State Hessen. We would, however, appreciate the chance to deal with your concerns before you approach an authority so please contact us in the first instance.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Data Protection Officer
Legally required Data Protection Officer
Data Protection Officer
WireMasters GmbH & Co. KG
Zum Sonnenberg 7-11
Telephone: +49 (0)60 51 60 60-49
Links To Other Websites
This Website may contain links to, and media and other content from, third party websites, plug-ins, and applications. These links are to external locations and third parties with which we have no relationship. If you click on an embedded third-party link, you will be redirected away from this Website to the external third-party website. You can check the URL to confirm that you have left this Website.
We cannot and do not (i) guarantee the adequacy of privacy, security, practice content or media provided by third parties or their websites, (ii) control third parties' independent collection or use or your personal data, or (iii) endorse any third party information, products, services or websites that may be reached through embedded links on this Website.
The Children's Online Privacy Protection Act ("COPPA"), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal data from and about children on the internet. Our Website and the services are not directed to children aged 16 or younger, nor is information knowingly collected from children under the age of 16. No one under the age of 16 may access, browse, or use the Website or provide any information to or on the Website. If you are under 16, please do not use or provide any information on this Website. If we learn that we have collected or received personal data from a child under the age of 16 without a parent's or legal guardian's consent, we will take steps to stop collecting that information and delete it.
For more information about COPPA, please visit the Federal Trade Commission's website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
Opposition to promotional emails
We hereby expressly prohibit the use of contact data published in the context of website legal notice requirements with regard to sending promotional and informational materials not expressly requested. The website operator reserves the right to take specific legal action if unsolicited advertising material, such as email spam, is received.
WireMasters GmbH & Co. KG
Zum Sonnenberg 7-11
Telefon: +49 (0)60 51 60 60-0